ECAR
Fact Sheet for Wisconsin
Mercury

Regulations
Self-Audit Checklist
Best Management Practices
Contacts
Related ECAR Fact Sheets
Other Relevant Resources
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The
following fact sheet was prepared by the ECAR Center staff. Once
prepared, each ECAR Center fact sheet undergoes a review process
with the applicable state environmental agency(ies). You can check
on the status of the review process here.
Please read the disclaimer on the status page. While we have tried
to present a summary of the essential information on this topic,
you should be aware that other items, such as local regulations,
may apply to you.
What You Need to Know
***NEW***
National
Mercury Switch Removal Program
In
late 2006, the Automotive Recyclers Association (ARA)
became a partner in the National Vehicle Mercury Switch
Recovery Program (NVMSRP) which is designed to remove
mercury convenience light switches from scrap vehicles
before the vehicles are flattened, shredded, and melted
to make new steel. It is intended to be a three year
cooperative effort among auto manufacturers, steelmakers,
dismantlers, shredders, US EPA, state representatives
of the environmental community and trade associations
of certain stakeholders. For more information see ARA
Governmental Affairs NVMSRP.
Under
this voluntary program auto recyclers agree to remove,
collect and manage the mercury switches from scrapped
vehicles. End of Life Vehicle Solutions (ELVS)
will carry out the program responsibilities for the
vehicle manufacturers. Click
here for more information.
NVMSRP
Participant/Related Documents/Participating Auto Recyclers
State
Mercury Switch Removal Information
NVMSRP
State Program
List
of Participating Recyclers WI
Mercury Sourcebook: Automotive |
A
recent study shows that releases from auto processing facilities
are the fourth largest source of mercury air emissions in the United
States. Most of the mercury in automobiles is found in the hood
and truck light switches. It is also found in some anti-lock braking
and navigational systems.
By
removing automotive mercury switches, Wisconsin auto and scrap recyclers
can prevent the potential release of almost 300 pounds of mercury
to our environment each year and help keep our lakes and rivers
free of mercury pollution. This assumes 300,000 cars are recycled
in Wisconsin each year and 43% have mercury switches. Only 1 gram
of mercury deposited by rain and snow each year can cause a fish
consumption advisory on a 20-acre lake. For every automotive mercury
switch recycled about 1 gram of mercury is removed from the environment.
The
Wisconsin Department of Natural Resources (WDNR) has prepared
a
guidance document to help auto recyclers manage mercury switch
removal. Much of that information is included in the fact sheet
below. You
can access the link to WDNR's Auto Mercury Switch Removal under
Other Relevant Resources.
Regulations
The
WDNR has partnered with Wisconsin auto and scrap recyclers to establish
a mercury switch recycling program, which is explained below. All
auto recyclers are encouraged to participate, as mercury switch
removal is not yet a requirement in Wisconsin. However there are
other rules for handling mercury switches which you must follow.
If
you choose not to participate in the mercury switch recycling program,
you have two options:
- Recycle
the mercury switches as a "Wisconsin-Specific Universal Waste." Hazardous
waste regulations for transporting, reporting, accumulation are
reduced under this policy.
- If
not recycling the mercury switches, you must comply with Wisconsin's Hazardous Waste Regulations.
The hazardous waste rules cover storage, transportation,
recordkeeping, and reporting. Depending on how much hazardous waste
you generate, you may need to obtain an EPA hazardous waste number.
For a complete review of these requirements see the RCRA Hazardous Waste Plain Language Guide.
If
you choose to participate in the mercury switch recycling program,
which is encouraged, you should comply with the following instructions
(more detailed instructions are contained in the mercury switch
recycling guidance document). This voluntary program is available
to auto recyclers at no cost. In addition, participants receive
a free HG spill kit (while supplies last).
Mercury
Switch Storage. Find
sturdy semi-clear, plastic containers with a tight-fitting lid.
You will need at least two containers if you are handling both metal
and glass switches. Store only one pound of mercury per container.
Labeling
and Marking. Keep
records of the number of switches you collect, date collection
started, date transported, origin and destination location. With
a permanent
marker (legal requirement), label the containers as follows as "Universal
Waste: Mercury Switches;" or, Waste: Mercury Switches;" or, "Used Mercury Switches."
Response
to Releases. Small spills are those involving
less than a dime-sized puddle of mercury metal. A large spill is
bigger than a dime-sized puddle and should be handled by hazardous
material cleanup professionals. For small spills, keep everyone
away from the area, turn off heaters, turn up air conditioners and
ventilate the area. If available, use a Mercury Spill Kit. If you
do not have a spill kit, refer to the mercury switch guidance document
for detailed clean up instructions.
Storing
Mercury Wastes. Mercury
wastes should be put in a vapor-proof, sturdy unbreakable container.
Anything that touched the liquid mercury should be considered contaminated.
Only testing by a qualified professional can determine whether clothing
and other items are safe to keep.
Crushing
Mercury Lamps and Switches.
Do not crush the switch. Keep glass switches separate from metal
switches in order to prevent breakage. Place some sort of cushioned
medium in glass switch storage container help prevent breakage.
Transportation. You may transport mercury switches if you send the switches to approved
collection sites, ensure that the containers are safely secured,
and comply with all federal and state DOT regulations. Proper handling
and recycling of mercury switches exempts you from certain DOT transportation
requirements if the switches are in packages of less than one pound.
Collection
Sites. Make sure you take your mercury switches to approved
collection sites, that you notify the collection facility of any
spills inside the container, and give the facility a copy of your
mercury switch collection records, or have the containers labeled
with that information.
Links
to the Regulations.
Use the following links to view the regulations pertaining to mercury.
Wisconsin Hazardous
Waste Regulations (NR 590.01-690.81)
Wisconsin Universal
Waste Regulations (NR 690)
Federal
EPA Standards Applicable to Generators of Hazardous Waste
Self-Audit
Checklist
When
an inspector comes to your facility, there are certain things
he
or she checks to see if you are in compliance with environmental
regulations. It makes good sense for you to perform a "self-audit" and
catch and correct problems before they result in penalties.
Also, there are some compliance incentives associated with
self-audits
(see Audit Policy Page).
Use
the following list to audit your mercury management program.
- Find and properly label containers and keep a record of the
number and type of switches collected.
- Gather
the necessary tools. A mercury spill kit is recommended.
- Protect
your employees and prevent spills by following proper storage
and containment procedures.
- Identify
which vehicles have mercury switches and other mercury devices.
- Remove
mercury switches from lighting device and if possibly, place
in container.
- Transport
container to approved mercury switch collection facility in
compliance with all federal and state DOT regulations.
- If
you spill mercury or break a mercury device of any kind, determine
if it is a small or large spill. If it is a small spill, use
a mercury spill kit or other recommended methods. If it is a
large spill, hire a hazardous cleanup professional.
Best
Management Practices (BMPs)
Most
regulations tell you what you have to do to be in compliance,
but
they don't explain how to do it. That's where "best management
practices" come into play. BMPs are proven methods that help
you to get into compliance and stay there.
The
following BMPs are recommended for management and disposal of vehicle
parts containing mercury:
- All employees who handle or manage mercury-added products
should be informed of proper handling and emergency procedures
for these products and for mercury.
- Remove all mercury switches from the vehicle as soon
as possible.
- Be careful not to break or puncture the mercury container
during removal.
- If a mercury-containing device breaks, clean it up with
a Mercury Spill kit or other recommended methods. If it is a large
spill, hire a hazardous cleanup professional.
- Store mercury switches in a leak-proof, closed container.
Store in a way that will prevent the capsules from breaking.
- Label storage containers with "Universal Waste: Mercury Switches;"
or, Waste: Mercury Switches;" or, "Used Mercury Switches."
- Be able to demonstrate that you have not had the devices
stored for more than one year. This can be done by keeping a log,
shipping papers, or by labeling storage containers with the accumulation
start date.
- Recycle mercury switches with an approved mercury device
collection facility.
Contacts
- For
more information, contact Wisconsin's DNR Auto Salvage Sector
Resource Specialist at
715-831-3263, or contact the WDNR
Regional Office in your area. For northern Wisconsin, call
715-635-2101 or 715-365-8900; West Central Wisconsin,
call 715-839-3700; Northeast Wisconsin, call 920-492-5800; Southeast
Wisconsin, call 414-263-8500; and, for South Central Wisconsin,
call 608-275-3266.
- All
spills should be immediately reported using Wisconsin's 24-hour
toll free hotline at 800-943-0003. If you discover a discharge
through analysis of soil or water, use the Hazardous
Substance Release Fax Notification Form.
Related
ECAR Fact Sheets
- Hazardous Wastes
Other
Related Resources
- Wisconsin
Auto and Appliance Mercury Switch Recycling Project
- Wisconsin
- Auto Mercury Switch Removal Guidance Document
- Wisconsin
- Auto Mercury Spills and Clean-Up Instructions
- Wisconsin
Local Public Health Department Listing
- Wisconsin's
Auto and Scrap Recycling Website
- Mercury
Switch Removal Procedure from Vehicle Hood and Trunk Lights
(Vermont document)
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